Jump to Navigation
Jump to Content

United States v. Spatig

ELR Citation: 47 ELR 20114
Nos. 15-cv-30322, (9th Cir., 09/13/2017)

The Ninth Circuit held that a trial court did not err in not allowing evidence of the defendant's diminished mental capacity in a case involving a criminal conviction under RCRA. The defendant was sentenced to 46 months in prison for storing more than 3,000 containers of paint and paint-related materials on his property without a hazardous waste permit. During the trial, the defendant sought to introduce evidence of his diminished capacity, but the government filed a motion to exclude the evidence. The court concluded that diminished capacity evidence is admissible only for specific-intent crimes and that the defendant was charged with a general-intent crime. The appellate court agreed and upheld the trial court's decision.